S.L. 123.146 Art. 2Arragements to have effect. The to conclude a fiscal evasion This Contracting 1. This Contracting the manner in 2. There income or on movable or paid by 3. The (a) in (b) in 4. The taxes that are in place of, the shall notify taxation laws. 1. For the (a) the territorial and the wherein in accordanc

It is hereby declared:

(a) that the arrangements specified in the Convention set out in the Schedule to this Order (hereinafter referred to as "the Convention") have been made with the Government of the Russian Federation with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of the Russian Federation:

(i) the tax on profits of organisations;

(ii) the tax on income of individuals;

(b) that it is expedient that those arrangements should have effect following the entry into force of the Convention and in accordance with the relevant provisions of the Convention;

(c) that the Convention shall enter into force on such date as may be announced by notice in the Government * Gazette.

* 22nd May, 2014 - see Legal Notice 150 of 2014. SCHEDULE

(Article 2) CONVENTION BETWEEN THE GOVERNMENT OF MALTA AND THE GOVERNMENT OF THE RUSSIAN FEDERATION FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL Government of Malta and the Government of the Russian Federation desiring Convention for the avoidance of double taxation and the prevention of with respect to taxes on income have agreed as follows:

Article 1 PERSONS COVERED Convention shall apply to persons who are residents of one or both of the States. Article 2

TAXES COVERED Convention shall apply to taxes on income imposed on behalf of a State or of its political subdivisions or local authorities, irrespective of which they are levied.

shall be regarded as taxes on income all taxes imposed on total elements of income, including taxes on gains from the alienation of immovable property and taxes on the total amounts of wages or salaries enterprises. existing taxes to which this Convention shall apply are in particular: Malta: the income tax; (hereinafter referred to as "Malta tax"); Russia:

(i) the tax on profits of organisations;

(ii) the tax on income of individuals; (hereinafter referred to as " Russian tax"). Convention shall apply also to any identical or substantially similar imposed after the date of signature of the Convention in addition to, or existing taxes. The competent authorities of the Contracting States each other of any significant changes which have been made in their

Article 3 GENERAL DEFINITIONS

purposes of this Convention, unless the context otherwise requires: the term "Malta" means the Republic of Malta and, when used in a geographical sense, means the Island of Malta, the Island of Gozo and the other islands of the Maltese archipelago including waters thereof, as well as any area of the sea-bed, its sub-soil superjacent water column adjacent to the territorial waters, Malta exercises sovereign rights, jurisdiction, or control with international law and its national law, including relating to the exploration of the continental shelf and exploitation natural resources;

(b) the term "Russia" means the Russian Federation; geographical sense, means all the territory of the Russian and also its exclusive economic zone and continental according to the UN Convention on the law of the seas (1982);

(c) the terms "a Contracting State" and "the other Contracting Malta or Russia, as the context requires;

(d) the term "person" includes an individual, a company and of persons;

(e) the term "company" means any body corporate or any treated as a body corporate for tax purposes;

(f) the terms "enterprise of a Contracting State" and "enterprise Contracting State" mean respectively an enterprise carried resident of a Contracting State and an enterprise carried on of the other Contracting State;

(g) the term "international traffic" means any transport by a operated by an enterprise of a Contracting State, except or aircraft is operated solely between places in the other State;

(h) the term "business" includes the performance of professional and of other activities of an independent character;

(i) the term "competent authority" means:

(i) in Malta: the Minister responsible for finance or representative; and

(ii) in Russia: the Ministry of Finance of the Russian Federation authorised representative;

(j) the term "national", in relation to a Contracting State, means:

(i) any individual possessing the nationality of a Contracting and

(ii) any legal person, partnership or association deriving such from the laws in force in a Contracting State.